Employment Intermediaries and Tax relief for Travel and Subsistence ? CIPP response to HMRC

02 October 2015

The CIPP Policy team joined with BDO LLP in surveying stakeholders to gather views on the subject of tax relief for Travel & Subsistence.

The consultation Employment Intermediaries and Tax Relief for Travel and Subsistence ran from 8 July and laid out a proposal that would see the removal of tax relief for workers travelling to their workplace where they are:

  • Supplying personal services
  • Engaged through an employment intermediary (including umbrella companies, certain employment businesses and personal service companies) and
  • Subject to (or to the right of) the supervision, direction or control or any person.

The timescale being worked to by HMRC is to see changes being implemented with effect from 6 April 2016.

The aspiration of HMRC to ‘level the playing field’ of workers as a principle is supported by the survey findings, which upheld fairness above all. We are extremely concerned however, at the timescale for delivery, which is short, even to an industry that is more than familiar with change.

We believe also that if, as HMRC appear to be suggesting, there is currently widespread abuse, through the delivery of non-compliant schemes that HMRC should look to be both consistent and visible with its enforcement activity.

There appears to be a perception that widespread policing by HMRC does not occur. Change to the rules will not remove the need for HMRC to actively enforce compliance.

Thank you to everyone who took the time to respond to this survey. To read the response in full please click below.

CIPP response to Employment Intermediaries and tax relief for Travel and Subsistence

Travel and subsistence: discussion paper
On 23 September 2015 a discussion paper was published that sets out the case for change to the current rules for tax relief on travel and subsistence rules. The policy team will be issuing a survey in due course and as part of their response work will also be looking to hold a Think Tank forum, please contact Samantha Mann by email to [email protected] if you are interested in being involved with this work.

Thank you


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